2000-04-03_PERMIT FILE - M2000002 (6)

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DORSEY & WHITNEY LLP Division of Minerals and Geology April 3, 2000 Page 2 a southeast to northwest direction. These studies indicate that the plume continues outside of Pinnacle's property and crosses below the lands affected by the Application. See Attachment 1. The plume has its origin on the Rocky Mountain Arsenal property, a National Priorities List Superfund site approximately 7,200 feet east southeast of Pinnacle's property. Pinnacle's groundwater studies, through interviews with the Tri-County Health Department, indicate that the plume contains diisopropylmethyl phosphonate (DIMP), a waste by-product of [he nerve gas GB (a/k/a sarin) as well as concentrations of several organic compounds including methylene chloride and other chlorinated volatile organic compounds; pesticides including parathion, DDTs, mala[hion and atrazine; and non- chlorinated hydrocarbons including ethylbenzene and xylene. The plume does not pose a health risk on Pinnacle's property because the depth of plume is great enough that constructing homes on that property will not disturb the plume. However, the depth of mining contemplated by the Application may well intersect the plume. The Application discusses that mining will release groundwater, which will be used in mining operations and discharged into the South Platte River (see Exhibit D). This release of groundwater, if the plume is intercepted, may in fact pose a significant health risk through the interaction of groundwater with humans, or through the airborne release of chemicals once the groundwater meets the air when it is routed across Old Brighton Road (Exhibit G). Lafarge has not disclosed the results of groundwater studies of the land affected by the Application. Rather, the Application baldly states that "no toxic materials" will be encountered in the mining (Exhibit E, page 7), and that "[due to the absence of any pollutants, groundwater quality monitoring is not required in this operation" (Exhibit E, page 8). If Lafarge has conducted even a minimal Phase I environmental review of [he lands affected by the Application, Pinnacle believes that the plume of materials from the Rocky Mountain Arsenal would have been discussed. Nothing that Pinnacle has seen in the Application discusses this issue, treats the subject of the plume, or discounts its potential risk to public health. If Lafarge has relevant information in this regard, it should be required to submit such information. B. Slope stability. The Application discloses that the mining face will be "nearly vertical" (Exhibit D), and that upon reclamation, the face will still have a 3:1 slope (Exhibit E). Pinnacle believes that the steepness of the reclaimed faces, descending into a water storage facility, may well pose a safety risk from landslides and slope failures to people who will become residents of the adjoining